Research Brief
Implementing CalWORKs
The Problem of Noncompliance
In response to the Personal Responsibility and Work
Opportunity Reconciliation Act of 1996 (PRWORA),
California created the California Work and Responsibility
to Kids (CalWORKs) program—a “work-first” program
that provides support services to help recipients move
from welfare to work (WTW) and toward self-sufficiency.
To encourage prompt transitions to these goals,
CalWORKs also imposes lifetime limits on receipt of cash
assistance by adults. Finally, CalWORKs devolves much
of the responsibility and authority for implementation to
California’s 58 counties, increasing their flexibility and
financial accountability in designing welfare programs.
The California Department of Social Services (CDSS)
contracted with RAND to independently evaluate the process (implementation) of CalWORKs and its impact (outcomes), at both the state and county levels.
In conducting the second process analysis, which
focused on CalWORKs’ implementation through early
December 1999, Jacob Klerman and his colleagues followed up on an issue that surfaced in the first year—the
problem of noncompliance.
NONCOMPLIANCE IS AN “EXIT ROUTE” FROM
CalWORKs
When policymakers think about how CalWORKs is
implemented, they tend to think in linear terms, as represented by the middle column in the figure. The sequence
of steps begins with the approval of the application, proceeds to orientation and appraisal, and then to Job Club.
For those who do not find a job through Job Club, assessment follows, and then the signing of a WTW plan and
assignment to a sequence of WTW activities designed to
overcome barriers to employment. If the recipient has not
found employment by the 18/24-month time limit (from
signing the WTW plan), the recipient then has a mandatory assignment to community service, which, unless
Approval
Exempt
Orientation/
appraisal
Self-initiated
program (SIP)
Job Club
No job/
assessment
Noncompliance
WTW activities
Sanction
18/24-month
time limit/
community
service
Vendor voucher
payment
60-month
time limit/
child-only grant
Job/postemployment
services
Leave aid/
transitional
services
employment is found, continues through the end of the
60-month lifetime limit.
However, the linear path is not the only one recipients
take; as the figure shows, noncompliance (to the left) and
employment (to the right) are “exit routes” from this linear path, with noncompliance being the undesired outcome under CalWORKs.
NONCOMPLIANCE IS A SERIOUS PROBLEM
How serious is the problem? Every county reports
high rates of no-shows. Most counties report that for any
given activity, between one-third and one-half (and sometimes as many as two-thirds) of recipients fail to attend
when instructed to do so. The problem is most salient at
Job Club, but it appears to occur at each step and in most
counties.
Using tabulations from September 1999 WTW 25
forms filed by county welfare departments (CWDs), we
can construct a “snapshot” of where participants fell within the paths shown in the figure. We estimate that 22 percent of the CWDs’ mandatory workload is on the linear
path; 29 percent is employed; and 20 percent is formally
noncompliant (including those sanctioned). But this 20
percent understates the magnitude of noncompliance.
Many participants are unaccounted-for, including the noshows for whom the county has not yet begun the formal
noncompliance process.
REASONS FOR NONCOMPLIANCE VARY
While the problem of noncompliance is clear, the reasons for it are less so. Our analysis suggests three reasons:
First, because of CWD deficiencies, recipients may not be
receiving or understanding notices, or they may have
either easily remediable but unaddressed barriers to participation (e.g., being unaware that the CWD will pay for
child care) or serious but unrecognized barriers (e.g.,
learning disabilities). Second, participants may be fearful
of participating in a WTW step (usually Job Club).
Finally, there is willful noncompliance—recipients simply
choose not to participate, perhaps because they are
already working “under the table” and participating (e.g.,
in Job Club) would force them to forfeit their jobs.
When recipients do not comply, sanctions that cut
recipient benefits can be used. Given the consistently high
reported rates of no-shows in early CalWORKs activities
and the provisions of the CalWORKs legislation, one
would expect high sanction rates. However, the rates tend
to be lower than expected. Our county interviews show
that at the beginning of CalWORKs, many counties were
simply too busy dealing with compliant cases to sanction;
even now, some counties are reluctant to sanction, preferring instead to encourage participation. Moreover, there
is widespread concern that the statutory adult-only sanction (for a family of three, the loss of $121 of the $626
grant) is too small to have the desired effect of discouraging willful noncompliance.
IMPLICATIONS FOR POLICYMAKERS
HOME VISITS AND SANCTIONS ARE OPTIONS FOR
DEALING WITH NONCOMPLIANCE
While home visits are a promising strategy for dealing
with the serious problem of noncompliance, they are timeconsuming, and, to be done properly, they require specially trained staff. As noted, many counties have pilot
home visit programs in place or under development, but a
universal home visit program—whether immediately following noncompliance or after imposition of sanctions—
would require committing major resources. Conducting a
multicounty, randomized experiment to identify the
effects of various home visit strategies is feasible and worthy of serious consideration.
Regardless of the cause, counties report that home visits—which many counties are implementing or piloting—
are a potentially useful strategy for dealing with it.
Observers claim that the interaction between a CWD staff
person and recipients during such home visits can help
identify and address CWD deficiencies. Home visits also
provide a natural vehicle for motivating compliance
among the reluctant and fearful. Finally, home visits can
help identify fraud—to determine, for example, if the
recipients are not available for a home visit because they
are working, if the children are not present, or if other
adults appear to be living in the household.
Whether counties should be given the option of a fullfamily, as opposed to adult-only, sanction requires weighing two considerations. First, the effect of a full-family
sanction on participation must be considered. While there
are claims (from the state of Hawaii and from a recently
suspended demonstration in San Mateo County) that fullfamily sanctions increase compliance, the formal evaluation evidence is mixed. Second, there are real concerns
about the effects of full-family sanctions on the children
the CalWORKs program is intended to protect. As the
results of several ongoing studies of full-family sanctions
become available, the state could revisit this option.
The research summarized in this Research Brief was carried out within RAND’s Labor & Population Program. Research results are described in detail in
MR-1177-CDSS, Welfare Reform in California: State and County Implementation of CalWORKs in the Second Year, Jacob Klerman et al., 2000 (416 pp.,
$25) and its accompanying Executive Summary, MR-1177/1-CDSS, (28 pp., $8). Both documents are available electronically at http://www.rand.org/CalWORKs
or through RAND Distribution Services (Telephone: 310-451-7002; FAX 310-451-6915; Internet: order@rand.org). Abstracts of RAND documents may be
viewed on the World Wide Web (http://www/rand.org). RAND® is a registered trademark. RAND is a nonprofit institution that seeks to improve policy and decisionmaking through research and analysis; its publications do not necessarily reflect the opinions or policies of its research sponsors.
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